Williams v. Civil Service Commission

166 N.W.2d 309, 15 Mich. App. 55
CourtMichigan Court of Appeals
DecidedApril 24, 1969
DocketDocket 2,347
StatusPublished
Cited by10 cases

This text of 166 N.W.2d 309 (Williams v. Civil Service Commission) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Williams v. Civil Service Commission, 166 N.W.2d 309, 15 Mich. App. 55 (Mich. Ct. App. 1969).

Opinion

Levin, P. J.

Plaintiffs are employees of the city of Detroit. They challenge the validity of rule VII promulgated by the city of Detroit civil service commission. The rules provides:

“All persons working in any branch of the City Civil Service shall reside in the city of Detroit.”

*57 The plaintiffs proceeded first by petition addressed to the commission. ' The commission held a hearing at which plaintiffs’ attorney argued their position, but no evidence was offered in support of the claims that the rule is irrational and, therefore, beyond the competence of the commission to promulgate and violative of the State and Federal constitutions.

The commission denied plaintiffs’ petition. Plaintiffs then filed a complaint with the circuit court. The circuit judge in a comprehensive opinion ruled that the city charter confers on the commission the power to promulgate rule VII and that it is not unconstitutional.

On this' appeal, plaintiffs state 2 questions:

1. Did the Detroit civil service commission exceed its power under the city charter by promulgating a general residence requirement for municipal employees?

2. Does a rule conditioning municipal employment on the requirement that the employee reside within the city’s boundaries violate constitutional guarantees of due process, equal protection and civil and political liberty?

As a general proposition courts will not reach a constitutional question if they can decide the case on nonconstitutional grounds, whether or not such grounds have been properly raised by the parties (see footnote 1). Neese v. Southern Railway Company (1955), 350 US 77 (76 S Ct 131, 100 L Ed 60); 16 Am Jur 2d, Constitutional Law, § 113, p 301.

In Alma Motor Co. v. Timken-Detroit Axle Co. (1946), 329 US 129, 132 (67 S Ct 231, 91 L Ed 128), the United States Supreme Court reversed and sent that case back to the Circuit Court of Appeals for consideration of a nonconstitutional question which *58 was (p 132) “neither considered nor decided by the court below, nor argued here.”

The court observed (pp 136, 137):

“If two questions are raised, one of non-constitutional and the other of constitutional nature, and a decision of the non-constitutional question would make unnecessary a decision of the constitutional question, the former will be decided. This same rule should guide the lower courts as well as this one.”

And later (p 142):

“The principle of avoiding constitutional questions is one which was conceived out of considerations of sound judicial administration. It is a traditional policy of our courts.”

- Thus, we should not consider the constitutional questions plaintiffs ask us to resolve in their favor until it is determined that the case cannot be decided on nonconstitutional grounds.

Returning to question 1, did the commission exceed its power by promulgating a general residence requirement? For reasons hereafter stated we hold that the commission did exceed its powers when it established a residence requirement as a condition of continuing employment. We intimate no opinion as to the commission’s power to adopt a general residence requirement as a condition of initial employment. 1

*59 Tlie general statement of the commission’s powers appears in Title 4, ch 2, § 7 of the charter. 2

*60 Section 11 provides for examinations:

“All applicants for offices or positions in said classified service, except those herein otherwise specified, shall pass an examination which shall be made public, competitive and free to all citizens of the United States, with specific limitations as to residence, age, health, habits and moral character, which shall be uniform as to each kind of work or occupation.” (Emphasis supplied.)

That the commission in fact enforces rule VII against nonresidents appears from its annual reports :

“Residence is continuously policed and all known cases of individual evasions * * * are regularly processed and resolved by this commission.” 1961 Annual Report of the Detroit Civil Service Commission, Pt 1, p 12. (Emphasis supplied.)

In the 11-year period, 1956 through 1966, a total of 36 employees were discharged' on grounds of non-residence. Twenty-eight were discharged in the last 5 years of that period. 1956-1966 Annual Reports of the Detroit Civil Service Commission. The interim annual report for 1967 details by city department the residence investigations “by a civil service investigator.” 3

The commission’s initiative in this area is beyond its authority, which is to (i) classify positions, (ii) hold examinations “with specific limitations as to residence” — the word “with” modifies the word “examination” and, thus, the phrase “with specific *61 limitations as to residence” relates only to examinations, not tenure in employment, (iii) prepare an eligible list, (iv) certify names to the appointing authority, (v) disapprove discharge of provisional appointees, consent to transfer of provisional appointees, (vi) set aside promotions it finds were made for reasons other than the “interest of the service” and discharges, etc., “made for political or for reasons other than the good of the service.” 4

The appointing authority, not the commission, decides when, if at all, to discharge an employee, rule VII, which seeks to impose a mandate on the appointing authority and to compel discharge for nonresidence, exceeds the power of the commission to promulgate or enforce.

In Delaney v. Detroit Board of Fire Commissioners (1928), 244 Mich 64, 66, a fire fighter was discharged by the fire department for “intoxication and *62 for the good of the service.” The civil service commission ordered him reinstated. The Supreme Court reversed. It held that under § 18 the commission “is limited to the determination of two questions:

“(1) Was the employee discharged for political or religious reasons, or

“(2) Was he discharged for other reasons than the good of the service.”

The Court held that the commission could not retry the issue of intoxication, that (p 67) the commission’s “business is to see that the departmental heads act in good faith, not to correct their judgment”:

“The board of fire commissioners has the power of appointment and the power of removal for any reason not prohibited by the charter.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Wexford County Prosecutor v. Pranger
268 N.W.2d 344 (Michigan Court of Appeals, 1978)
People v. Vanderford
258 N.W.2d 502 (Michigan Court of Appeals, 1977)
Gantz v. City of Detroit
220 N.W.2d 433 (Michigan Supreme Court, 1974)
Gantz v. City of Detroit
210 N.W.2d 459 (Michigan Court of Appeals, 1973)
Huntley v. Motor Wheel Corp.
188 N.W.2d 5 (Michigan Court of Appeals, 1971)
Williams v. Civil Service Commission
176 N.W.2d 593 (Michigan Supreme Court, 1970)
Wayne Circuit Judges v. Wayne County
167 N.W.2d 337 (Michigan Court of Appeals, 1969)

Cite This Page — Counsel Stack

Bluebook (online)
166 N.W.2d 309, 15 Mich. App. 55, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-civil-service-commission-michctapp-1969.